Menu9/9/16: Every industry faces unique compliance challenges and operational risks but the modern healthcare industry – hospitals, insurance companies, healthcare professionals, even life science companies – are walloped on all sides by regulatory and legal risks. In a post on his Corruption, Crime & Compliance blog, Michael Volkov focuses on some of those risks, writing, “Looking over a healthcare organization’s risk profile means considering the application of the Anti-Kickback statute, Stark Self-Referral, False Claims Act and HIPAA privacy rule to the organization’s activities.” Fortunately, Volkov offers help in how healthcare organizations can move through the complex business of accurate risk assessment. He writes, “Starting with each general category for a relevant law, a risk assessment has to focus on financial relationships, information collection, storage and use, and patient reimbursement and revenue cycle issues.”
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9/9/16: Say what? The Tudors and Henry VIII were many things, but characters capable of teaching something about modern compliance? They are exactly that in the hands of Tom Fox who brings readers through a pointed history lesson before concluding that it “… illustrates a key theme of compliance programs. It is that compliance programs must be flexible and have the ability to evolve.” Fox goes on, “Simply put, it is not in the business interest of US companies (or others subject to the Foreign Corrupt Practices Act [FCPA]) to have a static compliance program. Compliance programs must have the flexibility to respond to a wide variety of factors, including changing market conditions both inside a corporation and on the ground.”
8/18/16: An excellent article published on Bloomberg BNA’s Corporate Law & Accountability Report digs into voluntary self-disclosure in the US and UK of corporate misconduct.
8/18/16: The Gibson Dunn 2016 Mid-Year FCPA Update is now available. As usual, it is one of the best, most thorough updates about FCPA actions. It’s also hefty. No light reading here but in addition to covering actions by the federal and state governments, it also gives a good review of global anti-corruption developments.
8/18/16: For Tom Fox, a trip to the dentist was the trigger for a post on FCPA Compliance & Ethics about the compliance profession and the talent for problem-solving. The post – as usual with Fox’ commentary – is thoughtful and thought-provoking.
